Corporate residence is determined on the basis of centres of activity, which may be the location of a company’s economic activity or management activity.
Centres of activity in Argentina of non-Argentine corporations are treated as PEs.
As part of the 2017 tax reform, a PE definition has been introduced into the Income Tax Law. Such a definition is generally aligned to the one included in the OECD's Model Tax Convention for the Avoidance of Double Taxation, although it is broader as it includes the performance of services by a non-resident provider, including services rendered by consultants, within the National Territory for a total length greater than six (months) within any 12-month period.
Last Reviewed - 19 February 2019